Clark R. Calhoun

When companies face state tax controversy and litigation matters before state taxing authorities, Clark provides practical representation and advice. With more than 10 years of experience, he has secured millions in tax refunds for clients.

Representing a national consumer markets company in a transfer-pricing dispute before the Georgia Tax Tribunal.

Representing a major billboard operator in a property tax appeal of the value of Times Square billboards.

Represented a Georgia health care entity in evaluating and successfully applying for a property tax exemption.

Secured a refund of Pennsylvania transfer taxes paid in connection with an alleged controlling-interest transfer.

Assisted a client in securing legislative language to clarify its entitlement to a state tax credit.

Represented Americans for Tax Reform in preparing and filing an amicus curiae brief to the U.S. Supreme Court in South Dakota v. Wayfair Inc.

Secured a refund of overpaid county 911 taxes by a telecommunications company.

Defended a company against an unprecedented use of alternative apportionment in Mississippi.

Represented the Institute for Professionals in Taxation in preparing and filing an amicus curiae brief to the U.S. Supreme Court, urging the Court to clarify federal jurisdiction in state tax administration.

Advised a national transportation company on federal excise tax issues stemming from a rewards program.

Represented multiple Georgia charitable organizations in securing property tax exemptions for property that was partially leased to for-profit entities, and was lead counsel in the seminal decision on such partial exemptions before the Georgia Court of Appeals in Piedmont Park Conservancy v. Fulton County Board of Assessors.

Performed a multistate review of the taxability of an advertising client’s services and advised the client on a resolution of its sales and income tax exposure.

Secured a multimillion-dollar sales tax refund for a manufacturer stemming from overpaid taxes on fuel.

In a stock transaction, negotiated a reduction of a client’s anticipated real estate transfer taxes by millions of dollars through revisions and review of the relevant laws.

Frequently reviews and resolves outstanding state income/franchise and sales and use tax issues in transactions involving cloud computing services providers.

Represented an industry-leading paint manufacturer in securing a refund of Georgia sales taxes associated with its distribution of color cards to customers.

Represented a group of leading Georgia charities in advocating for the Georgia Supreme Court to adopt a favorable interpretation of a crucial property tax exemption.

Defended two Fortune 500 entities against multimillion-dollar assessments and in seeking refunds of Mississippi income and franchise taxes.

Appealed and resolved numerous assessments of local business license taxes in Atlanta, Los Angeles, and other localities.

Assists clients with purchases and sales of state film tax credits.

Clark Calhoun has represented clients in state tax controversy and litigation matters before state taxing authorities, county boards, state trial and appellate courts, and the U.S. Supreme Court. Representative matters include the securing of a multimillion-dollar income tax refund in a Georgia Tax Tribunal action, receiving a refund of overpaid 911 taxes, defending a company against an unprecedented use of alternative apportionment, and earning a property tax refund for a charitable client.

In addition to state tax controversy matters in Georgia, California, and other states, Clark also represents clients on multistate sales/use, income, property, and transfer tax issues that arise in corporate stock and asset transactions, and he has negotiated voluntary disclosure agreements with nearly every state in the country.

Clark serves on the State Tax Notes advisory board and was the subject of its “State Tax Spotlight” in 2017. He is past chair of the State Bar of Georgia Taxation Section and was a significant contributor to a task force responsible for the creation of the Georgia Tax Tribunal. He is also a past chair of the IPT Report’s Editorial Committee and has been honored by IPT for “Article of the Year” and as “New Member of the Year.” Clark has been named to the Super Lawyers “Rising Stars” list in Georgia and has been recognized in Chambers USA: America’s Leading Lawyers for Business.